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The ATO’s draft guideline PCG 2025/D2 outlines how taxpayers must determine an arm’s length debt amount for related-party loans under transfer pricing rules. It challenges the use of guarantees to inflate borrowing capacity and introduces a risk assessment framework to classify arrangements by compliance risk. Robust documentation is essential to support deductions.

This report explores the key tax considerations that arise throughout the lifecycle of a typical M&A transaction, from initial planning through to final stages of execution.

The Australian tax landscape for multinationals has significantly shifted with the implementation of the Debt Deduction Creation Rules (DDCR) (in Subdivision 820-EAA of the ITAA 1997).

ADIs are navigating regulatory reform, digital transformation, and rising fraud risks by strengthening governance, modernising infrastructure, and aligning strategy with compliance to drive resilience and long-term value.

Discover how detailed M&A contract reviews can impact tax outcomes, ensuring efficient and risk-free transactions.

Stay informed about key updates impacting payroll and employment taxes, including the end of the FBT exemption for plug-in hybrid electric vehicles, new pay-day superannuation rules, and FBT year-end compliance tips. Learn how to navigate these changes effectively.

Updates to Foreign Resident Capital Gains Withholding (FRCGW) rules effective 1 January 2025 increase the withholding tax rate to 15% and remove the $750,000 threshold, applying to all Taxable Australian Property transactions. These changes aim to boost tax compliance for property deals. Find out more how to manage your obligations and avoid penalties.

Australia's Parliament has passed the Pillar Two rules, aligning with the OECD's global initiative to establish a 15% minimum tax rate for large multinational enterprises (MNEs).

Treasury is taking steps to ensure fairer tax treatment for foreign resident investors by tightening Australia's foreign resident Capital Gains Tax (CGT) regime. Proposed changes aim to broaden the CGT base and enhance integrity, impacting infrastructure, energy, agriculture, and more.

The employment taxes landscape in Australia is constantly evolving. There has been increased focus from the Australian Taxation Office and State Revenue Offices, leading to a rise in employment tax compliance audits.

Explore the impact of the latest ATO Draft Taxation Ruling on software and IP payments. Learn how overseas providers and taxpayers may be affected by changes in the ‘royalty’ definition, transfer pricing, and withholding tax rates. Understand the Commissioner's perspectives on royalties, copyright definitions, and tax treaty applications. For personalised guidance on adapting to these changes, connect with the Grant Thornton tax team.

The recent Court decision in the Bechtel Australia Pty Ltd v FC of T 2023 (the Bechtel case) ruling that fly-in-fly-out (FIFO) employees’ travel is deductible, has created a shift in the treatment of travel expenses for workers in mining, gas, transport and other industries. This ruling contrasts with the John Holland Group Pty Ltd v Commissioner of Taxation [2015] FCAFC82 (the John Holland case), causing notable effects.